Anthony M. Augusta, proceeding pro se, filed a complaint in the United States Court of Federal Claims seeking redress for the denial of his service-connected disability benefits claim by the Department of Veterans Affairs and for alleged improprieties during the processing of his applications. Augusta has a history of litigation with the Claims Court, having filed at least two prior suits, Augusta I and Augusta II, which concerned the same general facts underlying his current claims. In this case, the government moved to dismiss, arguing the Claims Court lacked subject-matter jurisdiction. The Claims Court granted the motion, concluding it lacked jurisdiction over Augusta's allegations and that his claims were precluded by res judicata principles. Augusta appealed this dismissal to the Federal Circuit.
The Federal Circuit reviewed the jurisdictional determination de novo. The court addressed Augusta's primary argument that the Claims Court erred in dismissing his constitutional due process claims regarding the improper processing of his VA claim. The court held that it is well-established that the Claims Court lacks jurisdiction over standalone due process claims because they do not constitute a money-mandating source of law. The court cited LeBlanc v. United States, noting that due process claims do not form a sufficient basis for jurisdiction because they do not mandate payment of money by the government. Since Augusta argued only due-process claims, he failed to identify a money-mandating source of law. Furthermore, the court reasoned that even if Augusta argued under the Tucker Act based on his underlying VA claim, Congress's statutory scheme for adjudicating VA benefits claims displaces Tucker Act jurisdiction. The court also addressed the res judicata argument, finding that Augusta failed to demonstrate these principles were inapplicable. The Claims Court had found that Augusta's complaint echoed claims made in his prior cases, Augusta I and Augusta II. In Augusta I, the court found Congress vested exclusive jurisdiction over veterans disability benefits cases with the Court of Appeals for Veterans Claims, and Augusta II disposed of his due process and takings claims for lack of jurisdiction. The Federal Circuit noted that Augusta's failure to perfect an appeal in these prior cases confirmed he was foreclosed from raising the same jurisdictional issues in this case.
The Federal Circuit's decision affirms the Claims Court's dismissal order, leaving Augusta barred from pursuing these specific allegations in federal court. The ruling reinforces the limitation that veterans cannot use the Tucker Act to bypass the exclusive jurisdiction of the Court of Appeals for Veterans Claims for disability benefit disputes. It also serves as a reminder that litigants with a history of prior litigation on the same facts may be precluded from relitigating jurisdictional issues under res judicata if they failed to appeal those prior decisions.
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